Kelly A. Lenahan-Pfahlert | lenahanpfahlertk@ballardspahr.com |  215.864.7311 | view full bio

Kelly focuses her practice on white collar defense and complex civil litigation.  Kelly has substantial experience in litigating BSA/AML issues on behalf of financial institutions relating to both discovery and liability, assisting with AML-related internal investigations

Banks and their employees face a difficult balancing act when discussing suspected fraud or money laundering activity with a customer on whose account activity the bank has filed a suspicious activity report (SAR).  The bank must take practical steps to protect the customer and the institution (for example, verifying transactions, restricting account access, or requesting…

President Trump’s May 19, 2026 executive order, Restoring Integrity to America’s Financial System, directs Treasury, FinCEN, the CFPB, and the federal banking agencies to reassess how financial institutions identify and manage risks associated with non-work authorized populations and related cross border financial activity. The order reflects a significant shift in federal expectations across…

President Trump issued Executive Order 14405 (the “Order”) on May 19, 2026 titled Integrating Financial Technology Innovation into Regulatory Frameworks. The Order directs federal financial regulators to review and update regulations, guidance, and supervisory practices to support financial technology innovation and reduce barriers to entry for non‑bank fintech firms. It follows earlier actions establishing…

Last month, the U.S. Department of the Treasury announced a new cybersecurity information‑sharing initiative led by its Office of Cybersecurity and Critical Infrastructure Protection (OCCIP). The program is designed to give eligible U.S. digital asset firms access to the same actionable cyber‑threat information Treasury already provides to traditional financial institutions. According to Treasury, the effort…

On April 8, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) issued a joint Notice of Proposed Rulemaking (NPRM) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The proposal would create a comprehensive anti‑money‑laundering/countering‑the‑financing‑of‑terrorism (AML/CFT) and sanctions compliance…

As part of the U.S. Department of Treasury’s efforts to modernize the U.S. anti-money laundering regulatory and supervisory framework, the Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would reform how financial institutions design and operate their anti-money laundering and countering the financing of terrorism (AML/CFT) programs. Though not a wholesale rebuild…

The U.S. Department of the Treasury has issued its first proposed rule under the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, marking a key milestone in federal efforts to regulate payment stablecoins. The Notice of Proposed Rulemaking (NPRM) outlines the principles Treasury will use to assess whether a state’s regulatory regime is…

On March 10, 2026, FinCEN issued a renewed and expanded Geographic Targeting Order (GTO) imposing enhanced reporting and recordkeeping requirements on certain money services businesses (MSBs) operating along the Southwest border. According to FinCEN, the action is intended to support law enforcement efforts to disrupt money laundering and bulk‑cash movement tied to Mexico‑based drug cartels…

In 2025, the Nevada Gaming Commission (Commission) and the Nevada Gaming Control Board (NGCB) launched one of the most significant enforcement waves in state history, imposing nearly $27 million in fines against three of the Las Vegas Strip’s largest operators: Caesars Entertainment, MGM Resorts, and Resorts World Las Vegas. Each case centered on failures to…

The prosecution of the developers behind Samourai Wallet illustrates how U.S. authorities are broadening their approach to privacy‑focused cryptocurrency tools. In April 2024, the U.S. Attorney’s Office for the Southern District of New York announced charges against Keonne Rodriguez, Samourai’s chief executive, and William Lonergan Hill, its chief technology officer. The indictment alleged that Samourai…